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Your Emergency Response Plan (q)(2)(iv) Safe Distances and Places of Refuge

The safe places of refuge (out-of-doors or shelter-in-place) should be the areas where an accounting of all employees will be performed. This can be critically important for identifying individuals that did not get out, estimating where they may be, and initiating any rescue operation. Information on safe places of refuge must be given to the…...

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Your Emergency Response Plan (q)(2)(iii) Emergency Recognition and Prevention

This is by FAR the most misunderstood element of all! The ERP must define the types of releases that could potentially require an emergency response and should define what types of releases would not be an emergency, or, in other words, what may be handled as an “incidental release”. The ERP should include an inventory…...

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Your Emergency Response Plan (q)(2)(ii) Personnel Roles, Lines of Authority, Training, and Communication

Personnel roles must be clearly defined in the ERP. One method of doing this is to list job titles and describe their projected roles in emergency response operations. Although specific HAZWOPER titles are not required, employees should be designated to assume duties that parallel 1910.120(q)(6) and must be trained accordingly. Lines of authority must also…...

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Your Emergency Response Plan Section (q)(2)(i) – Pre-emergency Planning and Coordination

We see a lot of great efforts on emergency response plans, but so many times folks just do not know the details OSHA will be looking for. Here are the required sections/information for your ERP and the details required.   (q)(2)(i) Pre-emergency Planning and Coordination    1) Does the plan address coordination with outside emergency…...

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Emergency Response & PSM Tip

Most of the facilities we work at have a mechanical integrity program for the process equipment. Most have a Work Order system for their preventative maintenance program. This system kicks out a work order for the PM(s) due. Most facilities track the closure rates of the PM W.O.’s. My tip… Add ALL of your emergency…...

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Better be thinking MOC before you do RBI

That is PSM lingo for…when you are utilizing Risk Based Inspection (RBI) protocols and you wish to extend the inspection or PM frequencies on a piece of covered equipment, this is without a doubt a change that REQUIRES an MOC…. Membership Required You must be a member to access this content.View Membership LevelsAlready a member?...

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Mechanical integrity management of bulk storage tanks

Following the Buncefield incident the importance of preventing loss of containment from bulk storage tanks has come to the fore. A significant factor in ensuring contained fluids are not accidentally released is the continuing mechanical integrity of the tank structure. http://www.hse.gov.uk/research/rrhtm/rr760.htm… Membership Required You must be a member to access this content.View Membership LevelsAlready a...

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Trick Question or legit question for PSM Compliance? Contractor Evaluations and PRCS Rescue Evaluations

OK, PSM requires us to evaluate our “contractors” who will be working on, in or adjacent to a covered process. OSHA’s Permit Required Confined Space Standard also comes into play during a PSM audit (see .119(f)(4)). Under the PRCS std. OSHA requires us to “evaluate” our rescue services (.146(k)(1)(i)-(ii)) using something similar to Appendix F…...

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What are “Temporary Operations” in regards to PSM Operating Procedures 1910.119(f)(1)(i)(C)

We always get the answer…”We do not have any temporary operations,” so that does not apply to us. A good auditor will educate the site personnel by taking them out to the field and finding a bypass around a control device. Then, we will ask for the “procedure” that is used when the bypass is…...

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The difference between a MOC and PSSR

Often we see facilities viewing MOC and PSSR’s management systems as DUPLICATIVE efforts. There is a distinct difference between these two PSM/RMP requirements. Basically, this is how it was so explained to me by Russ Evanston, one of the founding fathers of PSM…. Membership Required You must be a member to access this content.View Membership...

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Staffing and Management of Change

OSHA and EPA are now citing for not doing MOCs on personnel changes!  The debate rages on for those living in the PSM/RMP world. Just this week, a client called me to help them with an audit finding they received in a third-party audit. The auditor wrote the finding that they were not considering personnel…...

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Nitrogen an ignition source…yeah right Mr. Safety Man!

Well I told you last week that I would scare the !@#$ out of a lot of you, so here it goes.  Nitrogen can be your ignition source if it is NOT applied and used properly…. Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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